Bethune v. Woodbury Police Department

Background

Jason Lavet Bethune filed a complaint and an application to proceed in forma pauperis, meaning to proceed without paying the ordinary filing fees. He alleged that, after he contacted law enforcement to report wrongdoing, Woodbury police officers assaulted and kidnapped him and brought him to Regions Hospital. He further alleged that hospital staff restrained him, interfered with his breathing, and repeatedly injected him. He alleged that he was not offered transportation when released from the hospital in freezing temperatures.

Bethune sought $333 million in damages from each defendant. He identified theories including assault of a disabled person, kidnapping, and criminal conspiracy, and alleged excessive force and a due-process violation. The court construed the complaint as attempting to bring claims under 42 U.S.C. § 1983, a federal civil-rights statute that permits claims for certain violations committed by state actors. Documents Bethune later filed were treated as notices rather than an amended complaint, so the initial complaint remained the operative pleading.

Court’s Analysis

The court stated that it could dismiss an action filed by someone seeking fee-free status if the action was frivolous or malicious, and that it had to dismiss claims over which it lacked subject-matter jurisdiction. A frivolous claim is one lacking an arguable basis in law or fact.

The court held that the Woodbury Police Department was not a legal entity that could be sued under § 1983. The same reasoning applied to “911 Washington County Sheriff” if that name referred to the Washington County Sheriff’s Office. The court also noted that Bethune alleged no facts showing the Washington County Sheriff’s personal involvement. Even if the complaint were treated as asserting claims against the City of Woodbury, the court said Bethune had not alleged an unlawful city custom or policy that could support municipal liability.

The court treated Regions Hospital differently because it was a legal entity that could be sued, but held that § 1983 applies only to state actors. The court concluded that Regions Hospital was not alleged to be a state actor and therefore could not be liable under § 1983 for the alleged conduct. As to the Post Board, Bethune alleged only that it had failed to act and provided no facts connecting it to the events. The court concluded that all of Bethune’s § 1983 claims were frivolous as pleaded.

The court found no other apparent federal-law claim. Because Bethune did not allege diverse citizenship, any remaining state-law claims could be heard only through supplemental jurisdiction, which allows a federal court to hear related state-law claims in some circumstances. After dismissing the federal claims before trial, the court declined to exercise supplemental jurisdiction over any state-law claims.

Disposition

Judge Wilhelmina M. Wright ordered that Bethune’s complaint be dismissed without prejudice. The court also denied Bethune’s application to proceed in forma pauperis as moot. The order directed that judgment be entered accordingly.